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U.S. Stimulus: Boon or Boondoggle for the Solar PV Market?

By Glenn Harris, SunCentric Incorporated
February 19, 2009   |   13 Comments

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13 Reader Comments
Comment
1 of 13
February 20, 2009
Perhaps you could clarify something about your calculations. It was my understanding that the grant would be calculated on the same tax basis as the ITC and is generally intended to mimic the ITC. Why is the basis for the grant not reduced for receipt of a state rebate as it is for the ITC?
Comment
2 of 13
February 20, 2009
Thank you Glenn for cutting thru the BS. There is really nothing here for solar. We don't need training programs or new dumb beauraucracies. We need the rebates to cover the cost of materials. Period. If they did that it would be off to the races and gas would be 25 cents a gallon in 5 years. How much influence did oil and gas have on this non incentive program. When we go rid of the oil man in Massachusetts, Mitt Romney, Governor Patrick simplified everything and increased the rebates. Still, we only have deep pocketed individuals or companies installing solar. We did it and have almost eliminated our heating bill as well as electric and A/C. This stuff works. I wonder if the Democrats are more in the back pockets of oil.
Comment
3 of 13
February 20, 2009
Justin,

The ARRA Repeals the Penalty for Subsidized Renewable Energy Financing . It allows businesses and individuals to qualify for the full amount of the solar tax credit, even if projects receive subsidized energy financing (e.g. below market loans, tax preferred bonds, state grants etc.). This amendment shall apply to periods after Dec. 31, 2008. (Div. B, Sec. 1103, p.36).

We'll check again but we're very sure that this applies to the new Federal grant as well.
Comment
4 of 13
February 20, 2009
Glenn,
Good piece, but I take issue with your assertion that "State" incentives must reduce taxable basis. If the supplier of the solar energy equipment or installation provides a rebate of costs, then yes, taxable basis must be reduced. But if the Incentive payment originates with a state-regulated utility not in any way involved in the construction, that subsidy should not reduce basis at all...as long as the incentive recipient takes the incentive amounts into income. Compare to a developer of tax credit affordable housing: receipt of a Section 8 operating subsidy contract does not reduce housing basis, and is recognized as income. In the case of solar, because of rapid depreciation, the incentive income is offset or sheltered. In any case, the grant in my view is equal to the ITC, and it opens the door to more investor/users of the subsidy, so more dollars should flow to solar.
David Kunhardt
Solar Power Partners, Inc
Mill Valley
Comment
5 of 13
February 20, 2009
Justin,
the example given is the "residential" case, where you obtain a cash, upfront rebate ($1.55/W). In that case - and only in that case - will you have to reduce your ITC basis by that incentive amount (in this example the $77,500). Typically, installers or equipment manufacturers will subtract those rebate payments from your invoice in order to reduce your out of pocket cash (you sign the rebates over to them).

In the "commercial" scenario, where you pay the full system price, the ITC is like the grant a full 30% of the system price. Here the rebates are paid as "PBI - performance based incentives" over time. You receive $0.22/kWh produced for 5 years. Because companies can utilize the depreciation, this is typically the more attractive scenario for businesses.

The depreciation basis is 85% of the system price.

Hope this helps...
Comment
6 of 13
February 20, 2009
David,

Don't think we're making a statement on the application of state incentives to the basis. We are concerned that federal grants, made to any system owner type in any state, will be treated as income in the state and then taxed by the state. We would very much like to find out that the states will not tax the Federal grant. What do you think?

In our modeling the 30% grant does not change payback in a meaningful way compared to the 30% ITC, so we're not sure why this will stimulate the market. Owners will likely still need to finance a significant part of the system, consume all the deprecation and have a healthy state incentive to make things work. If it had been a 40 or 50% federal grant - different story.
Comment
7 of 13
February 21, 2009
@Glenn:
What's your take wrt residential PV installs? Will the Fed rebate change from ITCs to grants? And are folks likely to get these grants early enough to dissuade the traditional EOY rush?
Comment
8 of 13
February 21, 2009
Jim,

Individual tax payers don't get to use the grant program. Darn it. The best way to think about ithe grant is that the system owner needs to be a for-profit business. It might be worth investigating the possibility of putting a system on a residence that is partially used for business...might at least need the utility bill to be in a business name? I'll leave the creative thinking to you, but we'll certainly get more clarity in coming weeks and months.

The 30% uncapped ITC is still available for individual taxpayers.
Comment
9 of 13
February 22, 2009
Your table is not correct. How can you say the 'out of pocket' cost is net of the 30% ITC? If you got a 50kw system tomorrow, you don't get that ITC until about a year from now, assuming you have the tax appetite. Your 'out of pocket' cost most certainly is not less the 30% ITC.

That's the main advantage of the grant, if it's payable in 60 days, then you can argue 'out of pocket' is gross cost - 30% grant.
Comment
10 of 13
February 22, 2009
Adam,

We tried to avoid the timing issue in the example and yes you might have to wait to recognize the ITC benefit, although if the system is completed in November or December the wait might be very short. Ultimately however you have "an out of pocket cost", in other words the unsubsidized amount of the system that a customer will pay. We think the chart represents this view correctly.

Also, the chart shows the change in the rules. A business that applies for a grant can now get 30% on the entire system cost. Formerly a customer had to reduce the system cost by, in this example the California rebate, and then calculate the 30% ITC.

Hope this helps clarify our point.
Comment
11 of 13
February 22, 2009
Glenn --

I appreciate your response to the question I posed. I think it should be clearly noted however, that the issue subsidized energy financing (and the recent removal) does not affect tax treatment of utility/state grant programs. These are two separate issues addressed in two separate portions of the tax code. Notwithstanding the removal of the incentive "haircut" for subsidized energy financing, an anti-doubledipping provision remains for non-taxable grants (26 USC 138).
Comment
12 of 13
February 22, 2009
Please quote the section in the bill that states individual taxpayers are excluded from the grants.
Comment
13 of 13
March 9, 2009
Glenn,

I read in another review of the stimulus bill that mentioned there was also the ability to take depreciation in two years if the taxpayer is under $15 million annual sales. Is this correct and could it help small PPA structures where the combined investors (doctors, lawyers etc) have less than $15 million revenues, or the PPA itself is a one off structure?

Gary Leger
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